Sponsored investment entities resident in a jurisdiction that has entered into a Model 1 intergovernmental agreement with the United States for FATCA (such as the Cayman Islands) that have US reportable accounts must be registered by their sponsoring entity with the IRS to obtain a GIIN by 31 December 2016. Cayman Islands sponsored investment entities that do not currently have (or have not had) US reportable accounts are not required to have a GIIN by this date but if US reportable accounts are identified then sponsors should obtain a GIIN within 90 days of first identifying such accounts. Cayman Islands sponsored investment entities should ensure that they select "Non-Reporting IGA FFI" on any W-8BEN-E forms and not "Sponsored FFI".

CRS - Approaching Due Diligence Deadline: 31 December 2016

Cayman Islands Reporting Financial Institutions are reminded that all Pre-Existing High Value Individual Accounts (i.e. accounts maintained with an aggregate balance or value greater than US$1 million as at 31 December 2015) must be reviewed to identify any CRS Reportable Accounts by 31 December 2016.

Draft Revised CRS Regulations Issued for Industry Comment

On 15 November 2016 the Cayman Islands Department of International Tax Cooperation issued draft revised CRS Regulations to industry for comment, and it is expected that these will be finalised early next year. The revised CRS Regulations will set out the penalties and enforcement powers for CRS compliance breaches. We shall provide a further update on these once they are closer to finalisation.

If you have any questions regarding your obligations, or if you require assistance with the notification or reporting process, please speak with your usual Maples and Calder or MaplesFS contact. Additionally, you may contact any one of the above members of our AEOI team. Further information is also available on our FATCA and CRS microsite.